middot;
2540 Huntington Drive, Suite 201
San Marino, 91108
237-2003
Fax:
Attorneys for Plaintiff
287-4540
Tel.: THE COURT AND ALL PARTIES THIS ACTION:
NOTICE HEREBY GIVEN THAT: case entitled Los Angeles Police Protective League City Los Angeles, Charles
Beck, and Does through .XX("Los Angeles Protective League"), which was filed about April 18, 2012, currently pending before this Court. Plaintiff herein believes that Los Angeles Protective League reiated case under
several subsections Rule 3.300 the California Rules Court. Rule 3.300(a){l) the California Rules Court provides that cases are related they
"involve the same parties and are based the same similar claims." Rule 3.300(a)(2) the California Rules Court provide that cases are related ifthey
"arise from the same substantially identical transactions, incidents, events requiring the
determination the same substantially identical questions law fact" The City Los Angeles and Charles Beck, Chief Police the Los Angeles Police
Department ("LAPD") are both Defendants Los Angeles Protective League and this matter. Los Angeles Protective League and this matter both involve Special Order entitled "Community Caretaking Doctrine and Vehicle Impound Procedures -Established," which was issued
Defendant Beck about April 10> 2012, and became effective April 22, 2012.
Both lawsuits contend that Special Order which purports regulate the impounding
vehicles the City Los Angeles "establish[ing] the procedures for impounding vehicles from
unlicensed drivers, and drivers with suspended revoked licenses the field, the scene traffic
collisions and driving under the influence (DUI) checkpoints," conflicts with provisions the -....
California Vehicle Code, including California Vehicle Code 14602.6 and 14607.6, which govern the
impounding vehicles driven unlicensed drivers. Both lawsuits seek declaratory relief, pursuant California Code Civil Procedure
1060, the form judicial detennination regarding whether Defendants their respective matters possessed lawful authority issue Special Order and whether the provisions Special Order
conflict with the California Vehicle Code, including California Vehicle Code 14602.6 and 14607.6.
Both lawsuits also seek injunctive relief prohibiting the enforcement Special Order
10. Pursuant Rule 00( the California Rules Comt, this notice being served all parties Los Angeles Protective League. See attached Proofof Service Mail. DATED: May i:.._, 2012
By:
San Marino, 91108
Tel.: (626) 287-4540
Fax: (626) 237-2003
JUDICIAL WATCH, INC.
425 Third Street, Suite 800
Washington, 20024
Tel.: (202) 646-5172
Fax: (202) 646-5199
Attorneys for Plaintiff
PROOF SERVICE MAIL employed the City San Marino, California. over the age and not party the within action. business address 2540 Huntington Drive, Suite 201, San Marino, 91l08. May 2012, served the foregoing document:
NOTICE RELATED CASE the interested parties this action placing true and correct copy thereof sealed envelope
addressed follows:
SEE ATTACHED SERVICE LIST MAIL: caused such envelope deposited the U.S. mail, with postage thereon fully prepaid, San Marino, CA. "readily familiar" with the firm's practice collecting and
processing correspondence for mailing. Under that practice, would deposited with the U.S. Postal Service that same day, with postage thereon fully prepaid, San Marino, the
ordinary course business. aware that motion the party served, service presumed invalid postal cancellation date postage meter date more than one day after date deposit for mailing affidavit. FEDERAL EXPRESS: placed such envelope for deposit the Federal Express drop slot for service Federal Express the next business day. "readily familiar with the firm's
practice collection and processing correspondence for mailing. Under that practice, would deposited with Federal Express that same day San Marino, CA. the ordinary course
business. aware that motion the party served, service preswned invalid service more than one day after date deposit for express service affidavit. PERSONAL SERVICE: delivered such envelope the offices the addresses(s) with delivery time prior 5:00 p.m. the date specified above. declare that employed the office member the bar this Court whose direction the service was made. declare under penalty perjury the laws the State California that the foregoing true
and correct and that this declaration was executed May
Plaintiff's Notice Related Case Page
SERVICE LIST
Counsel for Plaintiff Los Angeles Police Protective League City Los Angeles, Charles Beck, and Does through XX:
Richard Levine, Esq.
SILVER, HADDEN, SIL VER, WEXLER LEVINE
1428 Second Street, Suite 200
P.O. Box 2161
Santa Monica, 90407-2161
Tel: (310) 393-1486
Fax: (310) 395-5801
Defendants Los Angeles Police Protective League City Los Angeles, Charles
Beck, and Does through XX:
Cannen Trutanich
City Attorney
LOS ANGELES CITY ATTORNEY'S OFFICE
City Hall East
200 North Main Street
8th Floor
Los Angeles, 90012
Tel: (213) 978-8100
Fax: (213) 978-8312